International

  • June 01, 2020

    IRS Updates FATCA Method Of Canceling Sponsoring Entities

    Sponsoring entities that help foreign financial institutions abide by the Foreign Account Tax Compliance Act must cancel other approved sponsoring entities that need to be removed, an update to the FATCA registration system announced Monday.

  • June 01, 2020

    Not Pursuing High-Income Nonfilers Costs $46B, TIGTA Says

    The IRS is leaving billions of taxes uncollected by not effectively pursuing high-income individuals who don't file returns, missing out on nearly $46 billion in a recent three-year period, the Treasury Inspector General for Tax Administration said Monday.

  • June 01, 2020

    IRS Seeks Input On Data Collection Studies, 2 Other Subjects

    The Internal Revenue Service is accepting comments on its data collection research, relief for failure to make an election on an estate tax return and a form used to determine foreign tax credits, according to notices released Monday.

  • June 01, 2020

    Wealth Manager Seeks To Trim Ex-Athletes' Negligence Suit

    A wealth manager urged a London judge Monday to consider paring down a group of former athletes' £15 million ($18.7 million) negligence suit before settlement talks begin, arguing that settling the limitations dispute first will give the mediation a better shot at success.

  • May 29, 2020

    Tax Incentives May Not Spur US Operations In Virus Fight

    The novel coronavirus pandemic has some members of Congress discussing tax policies that could entice multinationals to bring manufacturing home, but those measures, including a slash in the corporate rate, may not make much difference in the current uncertain climate.

  • May 29, 2020

    Digital Taxes Face International Legal Gantlet

    Special taxes on digital companies seem almost inevitable as the novel pandemic heightens focus on the tech sector, but they could face legal challenges under both international trade and tax rules as countries begin to collect.

  • May 29, 2020

    China Deferring Most Small-Biz Tax Payments Until 2021

    China announced Friday that it will let small businesses, microenterprises and low-profit companies postpone paying taxes until 2021 in an attempt to help them survive the novel coronavirus pandemic.

  • May 29, 2020

    IRS Urged To Clarify Tax Benefit Reductions In Hybrid Regs

    The finalized version of proposed Internal Revenue Service rules on hybrid arrangements should clarify that accounts used to track dividends from foreign affiliates are reduced when deductions are reduced under foreign tax jurisdictions, Molson Coors said in a recent letter.

  • May 29, 2020

    Dutch Plan To Tax Dividend Outflows To Curb Abuse

    The Netherlands plans to begin levying in 2024 a withholding tax on dividends paid into low-tax jurisdictions to curb what a senior Dutch government official on Friday called a problem among multinational companies that's worse than previously estimated.

  • May 29, 2020

    Taxation With Representation: White, Freshfields, Fenwick

    In this week's Taxation With Representation, Panasonic takes a minority stake in supply chain company Blue Yonder, private equity firm Goldfinch Partners takes a majority stake in fintech services provider Vesta, and Coinbase acquires crypto-focused prime brokerage platform Tagomi.

  • May 29, 2020

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly Internal Revenue Bulletin on Friday, highlighting final rules on stripping earnings, proposed rules that would heighten reporting standards for tax-deductible fines and penalties and an agency announcement on NAFTA.

  • May 28, 2020

    Pandemic Pushing Gov'ts To Rethink Tax Policy, Panel Says

    Making tax systems more progressive has become an imperative as countries consider how to rebuild their pandemic-battered economies, and urgency could make this goal politically salable, a panel of experts agreed Thursday.

  • May 28, 2020

    Electronic Device Supplier May Owe Tax To Romania, ECJ Says

    An electronic device supplier may be liable for additional taxes in Romania after the European Court of Justice ruled Thursday that national tax authorities can adjust the amount of deductions claimed on discounted supplies.

  • May 28, 2020

    Gabbard Says German States Wrongly Taxing US Service Members

    Some German states have started taxing the military income of U.S. service members stationed in the country, violating a NATO treaty, U.S. Rep. Tulsi Gabbard said in a letter to several U.S. government officials.

  • May 28, 2020

    OECD Pro Says Developing Nations Face Tax Data Hurdles

    Developing nations seeking revenue to respond to the novel coronavirus pandemic face data-processing challenges with their residents' offshore tax information after obtaining it through a global exchange system, a specialist with the Organization for Economic Cooperation and Development said Thursday.

  • May 28, 2020

    Tax Court Finds Atty, Wife Owe Penalties For Underreporting

    An experienced attorney and his wife are liable for penalties for failing to report large amounts of income to the Internal Revenue Service and for claiming deductions that weren't available to them, the U.S. Tax Court said Thursday.

  • May 28, 2020

    Failed Trade Negotiations Cast Shadow On Global Tax Talks

    A failed multilateral trade deal and a yearslong dispute between the U.S. and the European Union over airline subsidies suggest current global negotiations on digital taxes could take years to achieve results.

  • May 28, 2020

    EU's Tax Commissioner Calls For More Ambitious Agenda

    The European Commission's top tax official on Thursday called for a more aggressive tax policy, something he said is necessary to maximize the benefits of a program announced the day before intended to help Europe rebound from the COVID-19 crisis.

  • May 27, 2020

    Ailing Foreign Aliens Can Get Residency Form Relief, IRS Offers

    The Internal Revenue Service said Wednesday that alien individuals don't immediately need a physician's statement if they fall ill and can't leave the U.S. but want to exclude time spent in the country from being counted toward residency.

  • May 27, 2020

    Walmart Pays Mexico $363M In Back Taxes From 2014 Deal

    Walmart Inc.'s division in Mexico said it has paid the Mexican government 8.1 billion pesos ($363 million) in taxes connected to its 2014 sale of the VIP's restaurant chain after a reassessment by the country's tax authority.

  • May 27, 2020

    COVID-19 Financial Relief Won't Be Taxed, Hong Kong Says

    Emergency novel coronavirus relief funds distributed from Hong Kong's HK$167.5 billion ($21.6 billion) anti-epidemic fund will not be subject to tax, a notice from the Inland Revenue Department said Wednesday.

  • May 27, 2020

    OMB Reviewing Final Rules On Deductions For FDII, GILTI

    The Office of Management and Budget is reviewing final rules that will govern tax deductions for foreign-derived intangible income and global intangible low-taxed income, according to a post on its website.

  • May 27, 2020

    EU Eyes Digital Tax To Fund Recovery From Pandemic

    The European Commission said Wednesday that it is eyeing a digital tax, as well as a tax on carbon, to help fund a program to help Europe rebuild after the novel coronavirus crisis.

  • May 27, 2020

    HMRC Ramps Up Use Of Dirty Money Powers To Freeze £20M

    HM Revenue and Customs has almost tripled its use of new powers over the past year to freeze and take back £19.5 million ($23.8 million) of dirty cash deposited by criminals in British banks, data published on Wednesday shows.

  • May 26, 2020

    OECD Chief Sees Unruly Result If Digital Tax Pact Fails

    The chief of the Organization for Economic Cooperation and Development warned that if it fails to broker a global agreement on taxing the digital economy, countries suddenly indebted by the COVID-19 pandemic will move unilaterally, potentially sparking trade wars.

Featured Stories

  • Tax Incentives May Not Spur US Operations In Virus Fight

    Natalie Olivo

    The novel coronavirus pandemic has some members of Congress discussing tax policies that could entice multinationals to bring manufacturing home, but those measures, including a slash in the corporate rate, may not make much difference in the current uncertain climate.

  • Digital Taxes Face International Legal Gantlet

    Alex M. Parker

    Special taxes on digital companies seem almost inevitable as the novel pandemic heightens focus on the tech sector, but they could face legal challenges under both international trade and tax rules as countries begin to collect.

  • Failed Trade Negotiations Cast Shadow On Global Tax Talks

    Todd Buell

    A failed multilateral trade deal and a yearslong dispute between the U.S. and the European Union over airline subsidies suggest current global negotiations on digital taxes could take years to achieve results.

Expert Analysis

  • NOL Carryback Rule Changes Bring Benefits For M&A Parties

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    New federal tax rules in the CARES Act, allowing the use of net operating loss carrybacks, bring previously unavailable tax benefits and negotiation opportunities for parties to mergers and acquisitions, say attorneys at Polsinelli.

  • Pandemic Elevates Cos.' Compliance Risks In Latin America

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    While Latin American governments respond to pandemic-related financial needs, multinational companies face elevated compliance risks from increased interaction with government officials, and new enforcement policies related to the misappropriation of funds, expedited government contracting, increased transparency and monitoring, and international cooperation, say attorneys at K&L Gates.

  • Distressed Debt Tax Opportunities For Foreign Investors

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    Foreign investors can earn tax-free interest income on distressed debt issued by U.S. companies, as long as they steer clear of income classification pitfalls, says Seth Entin at Holland & Knight.

  • Pandemic Complicates OECD Digital Tax Overhaul

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    The Organization for Economic Cooperation and Development's decision last week to extend the deadline for a digital economy tax rewrite highlights novel pandemic-prompted issues that will need to be resolved, including the treatment of losses and an ideological debate between pro-growth and revenue-focused policies, says Joyce Beebe at Rice University.

  • Tips For Non-US Entities Facing Tax ID Processing Delays

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    Non-U.S. entities applying for taxpayer identification numbers during the pandemic, while IRS phone and fax lines are inoperative and mail processing is on hold, may need to employ alternative strategies to open bank accounts and meet tax filing requirements, say David Shapiro and Shane Hoffmann at Fried Frank.

  • Adapting 2020 Tax Expectations To COVID-19 Developments

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    Attorneys at Steptoe & Johnson consider unexpected international, federal and state tax developments that have occurred in response to the global pandemic, how they may impact individuals and corporations, and what measures may follow.

  • Key Tax Considerations For Secondary Sales Of Private Funds

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    Investors considering selling fund interests in the secondary market to create liquidity during the pandemic-related economic crisis should consider several tax and structuring issues that can impact the buyer, seller and the underlying fund, say attorneys at Mayer Brown.

  • Safeguarding Foreign Investments During A Pandemic

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    Investment agreements can protect foreign holdings when governmental measures in response to COVID-19 are overly restrictive, unnecessarily protracted or discriminatory, say attorneys at Ropes & Gray.

  • Calculating Credit Spreads During A Pandemic

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    Given the coronavirus-induced spike in credit spreads and the heightened regulatory scrutiny of intercompany financing, multinationals with significant debt should carefully review the arm's-length interest rates in their loan agreements to avoid double taxation, says economist Harold McClure.

  • 10 Insights Into IRS Audits And Appeals Amid COVID-19

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    Crowell & Moring attorneys David Fischer and Teresa Abney consider the top 10 things taxpayers and practitioners need to know about a series of recently issued Internal Revenue Service notices and employee memos addressing audit and appeals procedure during the pandemic.

  • Allocating Loss When COVID-19 Disrupts Your Supply Chain

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    Multinational enterprises experiencing coronavirus-related supply chain disruptions should take a few immediate steps to determine which entities should bear the losses of these disruptions for tax purposes, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.

  • Employers Should Consider Tax Impact Of Virus Relief Checks

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    The relief checks provided by the Coronavirus Aid, Relief, and Economic Security Act will introduce additional tax complications for companies with U.S. employees stationed abroad and foreign employees working in the U.S., says Richard Tonge at Grant Thornton.

  • How OECD Reconciles Int'l Tax Laws And Work During COVID

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    The Organization for Economic Cooperation and Development’s guidance this month clarifying international tax law principles, such as permanent establishment, in light of coronavirus-related work disruptions was an unusual — but welcome — first step toward preventing potential tax disputes, say attorneys at Bonelli Erede.